1 before the International Court of Justice stemming from the Rohingya genocide, Facebook is at 2 this very moment taking aggressive measures to conceal evidence of its involvement.10 3 28. Perhaps the most damning example of Facebook’s continued failure in Burma is 4 the ongoing—to this day—misinformation campaign being carried out on Facebook within the 5 country. As reported by Reuters on November 2, 2021, the Myanmar military has 6 tasked thousands of soldiers with conducting what is widely referred to in the military as “information combat” … The mission of the social media drive, part of the military’s broader propaganda operations, is to spread the junta's view among the population, as well as to monitor dissenters and attack them online as traitors, … “Soldiers are asked to create several fake accounts and are given content segments and talking points that they have to post” … In over 100 cases, the messages or videos were duplicated across dozens of copycat accounts within minutes, as well as on online groups, purported fan channels for Myanmar celebrities and sports teams and purported news outlets … Posts often referred to people who opposed the junta as “enemies of the state” and “terrorists”, and variously said they wanted to destroy the army, the country and the Buddhist religion.11 7 8 9 10 11 12 13 29. At the core of this Complaint is the realization that Facebook was willing to trade 14 the lives of the Rohingya people for better market penetration in a small country in Southeast 15 Asia. Successfully reaching the majority of Burmese people, and continuing to operate there 16 now, has a negligible impact on Facebook’s overall valuation and bottom line. Without the 17 18 19 20 21 22 23 24 25 26 In a glaring example of Facebook’s failure to learn from its deadly mistakes in Burma, Haugen has provided documents demonstrating that history is currently repeating itself in Ethiopia, where acts of ethnic violence are being carried out against the Tigrayan minority amidst a raging civil war, again with the help of a Facebook-fueled misinformation and hatespeech campaign. See Facebook is under new scrutiny for it’s role in Ethiopia’s conflict, NPR (Oct. 11, 2021), https://www.npr.org/2021/10/11/1045084676/facebook-is-under-new-scrutinyfor-its-role-in-ethiopias-conflict. See also Mark Scott, Facebook did little to moderate posts in the world’s most violent countries, POLITICO (Oct. 25, 2021), https://www.politico.com/news/2021/10/25/facebook-moderate-posts-violent-countries-517050 (“In many of the world’s most dangerous conflict zones, Facebook has repeatedly failed to protect its users, combat hate speech targeting minority groups and hire enough local staff to quell religious sectarianism”). 10 Robert Burnson, Facebook’s Stance on Myanmar Genocide Records Assailed by Gambia, BLOOMBERG (Oct. 28. 2021), https://www.bloomberg.com/news/articles/2021-10-28/facebook-sstance-on-myanmar-genocide-records-assailed-by-gambia. 11 27 28 Fanny Potkin, Wa Lone, 'Information combat': Inside the fight for Myanmar’s soul, REUTERS (Nov. 2, 2021), https://www.reuters.com/world/asia-pacific/information-combatinside-fight-myanmars-soul-2021-11-01. CLASS ACTION COMPLAINT 10 Case No. __________________